Health Canada’s NHP Fee Proposal Delayed — What This Means for the TCM Profession

As part of our ongoing advocacy on behalf of the Traditional Chinese Medicine community, the ATCMA has been actively involved in Health Canada’s consultations regarding the proposed cost recovery fees for natural health products (NHPs). We want to update our members and the broader profession on an important development — one that brings positive news for the future accessibility and affordability of Chinese herbal products in Canada.

Health Canada originally launched a public consultation on May 12, 2023, to gather feedback on its Proposed Fees for Natural Health Products. After receiving significant input, Health Canada published a revised fee proposal on March 27, 2024. This version outlined a seven-year phased implementation starting December 1, 2025.

ATCMA has been involved in conversations with Health Canada and the Non-Prescription and Natural Health Product Directorate (NNHPD) to share concerns about how these fees would impact the Traditional Chinese Medicine profession and the patients we serve. 

The great news is that the NHP cost recovery will not take effect on December 1, 2025. 

The proposed fee structure would require distributors and manufacturers to pay fees per NPN product. For the TCM sector — which relies on a large variety of single herbs and formulas, many of which serve smaller patient populations — this would create significant pressure. Costs would likely increase across the supply chain, making herbs more expensive for clinics and patients. In addition, if/when this goes through, companies may be forced to stop importing or producing lower-volume herbal products simply because they won't be able to justify the added expenses. This would reduce access to important herbs and formulas that practitioners rely on for individualized care.

The current pause means these impacts will not occur in the near term, preserving both affordability and product availability for our profession and the patients we serve.

This delay is linked to the federal government’s broader Red Tape Review, which called on departments to reassess their regulations and administrative processes. As part of this initiative, Health Canada and the Public Health Agency of Canada published their red tape reduction report on September 8, 2025.

The report outlines several regulatory modernization commitments, including:

• Introducing a simplified registration process for certain NHPs and non-prescription drugs (NPDs)

• Reducing pre-market requirements where post-market oversight is more appropriate

• Implementing flexible, risk-based vigilance requirements

• Allowing more adaptable labelling rules for NHPs

• Creating modern, streamlined regulations for NPDs to accelerate approvals

Health Canada’s immediate focus is on advancing these changes. The NHP cost recovery proposal will be revisited only after the updated regulatory framework is clarified, as these adjustments will impact program costs and design.

These changes will take time, and the ATCMA has been invited by the NNHPD to continue to represent the needs of our profession. We will keep our members informed as new information becomes available and continue advocating to protect access to safe, affordable, high-quality Chinese herbal products in Canada.